Brown v.
Board of Education encouraged the Civil
Rights Movement and paved the way for key civil rights legislation
in the 1960s, forever weakening Southern politicians' hold
on Congress, former NAACP lawyer and director-counsel Jack
Greenberg said in his keynote address at a symposium
Feb. 20 honoring the landmark Supreme Court decision that ordered
an end to school segregation in 1954. Greenberg, who was just
shy of his 28th birthday when he argued before the Supreme Court
in Brown, worked for the NAACP Legal and Educational
Defense Fund (LDF) for over 30 years and headed the organization
when Thurgood Marshall left to join the Supreme Court. He discussed
the questions he most frequently faces about the strategy of
the LDF and the consequences of Brown at the event,
sponsored by the Virginia
Law Review and the Center
for the Study of Race and Law.

Greenberg compared the political landscape before Brown
to a frozen sea. Southern senators controlled House and Senate
committees, and they depended on suppressing black votes to maintain
power. "Brown was like an icebreaker that broke a
pathway through that frozen sea," he said. He called the
results of Brown "mixed" today-we have 40 black
congressmen, but black unemployment is double that of whites;
there are 10,000 black law students across the country, but black
male longevity in Harlem is less than in Bangladesh. "But
before 1954 the picture was unmixed," he said. Brown
opened the path for the frozen sea to help make the successes
possible, but even the path through the frozen sea contains ice
floes and ice bergs."

Plaintiffs who sought justice in the five cases comprising Brown
for the most part just wanted a better education for their kids,
Greenberg said. "I don't think we ever filed a case to make
a political point," he said. "There may have been political
points coming out of the case."

In the build-up to Brown, LDF cases forced law schools
to accept blacks and successfully challenged "white primaries,"
which prevented African-Americans from voting. "They were
building blocks in fashioning a legal regime of full equality.
"There was no overall scheme," he added. "While
not ad hoc, it was an effort to use resources where they would
be most effective in kind of an impressionistic sort of way."

At the time, some said the LDF should press for equalization
rather than integration, but "those were voices that were
few and far between in what could loosely be called the civil
rights community." The LDF initially sought court orders
requiring equalization, "but that was not the final goal."
Even when courts ordered schools to have equal white and black
schools, schools were not equalized. "They just had to
keep going back to court again and again," Greenberg said.

"The debate over whether to seek separate but equal was
over long before I came to work at the Legal Defense Fund in 1949,"
Greenberg said. "Until 1950 the lawyers tactically, at least,
did not press for it."

Greenberg worked with Harvard Law graduate Louis L. Redding,
an African-American lawyer who practiced in segregated Delaware,
on the case Gebhart v. Belton, which became one of the
five cases included in Brown. Redding hated segregation,
Greenberg said; he worked in Delaware, but wouldn't live there
or visit on the weekends. Their case revolved around a woman who
had to drive her daughter to school because no transportation
was provided for blacks. "She just wanted her child to ride
the white school bus," he said. When Redding said he would
only sue if the goal was integration, "she readily agreed.

"Probably most plaintiffs did not start out seeking integration,
but all agreed to go along," he said. "We the leadership
wanted an end to segregation."
The LDF focused its strategy on schools because government employers
had an impenetrable set of rules and a far-reaching effect could
not be expected, and similar problems would result if the strategy
focused on housing, which was mostly private. "Schools
on the other hand, were clearly state action, and covered large
units.

"We hoped to have school segregation declared unconstitutional,"
he said. "I have to confess we did not think beyond that."
If successful, they suspected that all state-sponsored segregation
would end as a result.

Although there was "not a lot of speculative talk"
among the lawyers about the decision, Greenberg said he suspected
the Supreme Court would support black aspirations. When the decision
came down in their favor, he said "I was surprised and I
assume others were too."

Even with Brown, schools integrated slowly or not at
all. African-Americans faced challenges in trying to get into
higher ed into the 1960s, let alone secondary and elementary
schools.
"Nobody expected immediate compliance," he said. After
Brown, Thurgood Marshall noted there were 200 countries
in Georgia-and the LDF would have to file a school desegregation
case in each one.

The Southern whites' backlash on many fronts-including decisions
to close schools rather than allow blacks to enter and attempting
to get integrationist lawyers disbarred-caught the NAACP lawyers
off guard. "We had not anticipated anything like that . .
. Nor had we anticipated interminable litigation in each case."

BrownII, handed down by the Court in 1955, ordered
schools to desegregate with "all deliberate speed."
Greenberg said he doubted whether the wording of the decision
caused a greater backlash from segregationists. "It is the
underlying racism that was at fault," he said.

African-Americans who did integrate registered an immediate jump
in academic performance, he said, noting that black children do
better in integrated settings that prepare them for the working
world as well.

Greenberg said his understanding of the case changed radically
this past summer when he observed the integration of the Romas,
or gypsies, in eastern Europe, where they historically have been
discriminated against and faced segregation in a fashion similar
to African-Americans.

The European Union's equivalent of Brown was the Race
Equality Directive, which required countries to integrate schools
for admission into the Union. "It just blew me away,"
he said of the integration process. "It was working smoothly."
In Bulgaria, social workers visited every Roma family, tutors
were provided for children who needed them, the government promoted
inter-cultural associations, and residents praised what was happening.
There's still some prejudice against Romas in eastern Europe,
and litigation is ongoing in some cases about school integration
or equalization there, he added.

After the experience in Europe, "I perceived that Brown
could not have accomplished what it should have accomplished unless
it had been within a political environment that was receptive,"
he said. "Brown had to create the environment in which
it could work. It was not decided in such an environment.

"The Supreme Court in Brown set a moral standard,"
while southern states defended segregation, cast it as a federalism
issue, and put up physical resistance. When their uprising was
crushed in Little Rock and other locations, "it became clear
they could not succeed in a physical war against the rule of law."

"This was the predicate for the Civil Rights Acts of the
sixties," he said. "I won't say it wouldn't have occurred
without Brown, but it wouldn't have occurred when it did,
and possibly not until a generation later."

When President Lyndon Johnson signed the Civil Rights Act of
1964 he mourned that the Democratic party would lose the South.
"He was right, but it also meant the death of a political
regime that upheld racism," Greenberg said. "So Brown
was a success in bringing the country . . . into a period of our
own Race Equality Directive."

Part of the relapse in recent years into segregated schools is
due to Supreme Court decisions ruling that desegregation ordinances
are no longer necessary once a school system has been desegregated
once, Greenberg said. The No Child Left Behind Act allows for
school transfers, but not across district lines, so segregation
can still occur between districts, but "the most daunting
problem is city suburban integration.

"What is most important is a national will to do something
about education," he said. Greenberg proposed an amendment
to the Act that would require national or state commissions to
impress upon the public the importance of integration, an arrangement
to encourage suburban integration as a "patriotic duty,"
and the funding to do so.• Reported by M. Wood

Gary Orfield denounced Milliken
v. Bradley and the resegregation of schools
that followed the 1974 decision.

Brown's Impact on Public Schools

School segregation decreased following the Brown decision
and the Civil Rights acts of the 1960s until it was checked by
what Harvard University professor of education and social policy
Gary Orfield called “hostile presidencies—Nixon and Reagan—and
the only explanation [for the success achieved] is
that the courts did it.

“The evidence is that the courts are powerful when they have
powerful policies,” said Orfield, who added that “public opinion
favors more action to integrate schools.”

Segregation declined until recent years. In 1968, 80 percent
of blacks attended intensively integrated schools but by 1988
the figure had dropped to 20 percent. “The South is the most
integrated region, but it's going backward rapidly now,” Orfield
said.

After 1991 all regions of the United States became more segregated “because
of authorization by the Supreme Court,” he said, referring to
its 5-to-4 ruling on Milliken v. Bradley, a 1974 decision
that said that segregationist practices in one district do not
warrant relief that involves non-segregating districts, thus
stopping remedial efforts at district boundaries and checking
the possibility that suburban students would be bussed into cities.

“Milliken is the great tragedy in school integration,” Orfield
said. “Re-integration is driven by residential segregation.”

Amy Stuart Wells studied
the effects of integration on a group of students who graduated
high school in 1980.

What segregation was accomplished happened on white terms, according
to Amy Stuart Wells, professor of Sociology and Education at
Columbia University Teacher's College, whose study of the Class
of 1980 from six high schools across the country looked at the
impact of integrated schools on the first children to experience
it from kindergarten through high school.

She told the story of how when two schools consolidated, the
formerly white school would not allow the students from the formerly
black school to display their trophies in the new school. The
controversy ruined black hopes that the new school represented
progress on race relations.

Whites were not interested in discussing race matters in the
schools, they contended that they were being colorblind in their
behavior and policies, and there were no curriculum changes.
Whites, she said, still got better access to honors classes and
gifted programs.

The Class of 1980 did report making cross-racial friendships
that included contact outside school, Wells reported. They feel
that what they learned about race is very important to them but
that the society they entered after graduation is less integrated
than their school was. The study showed that whites from integrated
schools are less fearful of blacks and blacks reported feeling “better
equipped with survival skills for the white world.” Both feel
they are less likely to be taken in by stereotypes about people.

Black parents learned that even though integration happened
on white terms, black children are better off in white schools
because “green follows white,” meaning that schools with whites
are more likely to be well-funded, Wells said.

Law professor Kevin Brown
said the Supreme Court should have acknowledged that segregation
hurt whites as well.

Progress was not better because the Supreme Court did not advance
the right rationale in making the Brown decision, said
Indiana University law professor Kevin Brown.

“Brown forced the Supreme Court to define the harm
done by segregation and they found psychological damage inflicted
only on blacks,” he said. “The road indicated but not taken is
that the psychological harm is to both races. If the court had
recognized this they would have proclaimed that it was not for
the benefit of black children but all children.

“A minority group develops guilt feelings to defend itself from
their sense of inferiority; whites were harmed by being taught
the false message for their own superiority,” he said.

Whites' built-in advantage in society is taken as evidence of
superiority, he contended.

He said the white applicants who challenged the University of
Michigan 's selection policies were the beneficiaries of 500
years of oppression of blacks; the right decision would not merely
have left existing policies intact but have expanded them. In
the Court's decision on Grutter, it reaffirmed “the
commonly held belief that standards have to be compromised in
order to enroll blacks,” Brown lamented.

“Society should not be blind to continuing discrimination,” he
said.

Pointing to Brown's unintended consequences, U.Va.
law professor James
Ryan said Brown helped make the
use of vouchers in religious schools possible.

Law professor Jim Ryan said
liberals may want to re-think school choice so they can influence
how its implemented.

More private schools were formed and grew in the South after
the Civil Rights acts of the 1960s, making a dramatic increase
in a decade, he said. Ryan quoted one school founder who said
he would have never dreamed of starting a school had it not been
for bussing. The desire to avoid integrated schools coincided
with some parents' feelings that schools were also becoming godless.
This led to affiliations between schools and churches such that
schools that started as segregation academies morphed into Christian
academies. Since Catholic immigration began in the 19 th century,
Protestant elites had strictly opposed public support for private
schools and even into the late 1960s the term private school
was a virtual euphemism for Catholic school, since 90 percent
of private-school students at the time were in Catholic schools.
But when Protestant evangelicals were faced with the need to
support their own schools “they flipped, did an about-face,” Ryan
said, and they formed alliances with Catholics to get public
money. That goal was abetted by a perceived decline in the academic
performance of public schools, so that when the Supreme Court
was asked to allow vouchers, they could be seen as neutral with
respect to religious denominations. “Southern resistance finally
won the war,” Ryan said, “because vouchers are allowing resegregation.” He
said an ironic twist of choice programs is that they could improve
integration by allowing parents to choose to send their children
to integrated schools.

Ryan said Milliken “reflects and augments suburban
power and represents a suburban veto to make sure their schools
stay separate from urban schools.”

Polls show high school students are 75 to 80 percent positive
about attending integrated schools and also show improvement
the attitudes of white parents about having their children in
integrated schools.• Reported by M. Marshall

Georgetown University law
professor Mark Tushnet pointed out the pitfalls of strategic
litigation.

Brown and the Civil Rights Movement

Brown's litigation campaign helped liberal lawyers
and interest groups realize that it was possible to advance individual
cases alongside political ideals, said Georgetown University
law professor Mark Tushnet during a panel examining Brown's effect
on the Civil Rights movement. The NAACP Legal Defense Fund's
campaign against the death penalty in the early 1970s offers
an example of such an attempt to change policies through litigation
of individual cases.

Brown exists as an image of the culmination of strategic
litigation, but lawyers have to consider their clients' interests,
Tushnet said. This can be problematic if the lawyer wants to
win to advance policies, but plaintiffs on death row “want to
win on any grounds possible.”

Lawyers generally are unable to control litigation campaigns
for several reasons. “The opponents will offer attractive settlements,” he
said, and “second, you can win the cases in the lower courts
and the other side may decide not to appeal.” Death penalty opponents
were winning case after case, “but only on statutory grounds”—not
on moral grounds. “It turns out the strategic litigation campaigns
are not terribly cost-effective,” he said.

Furthermore, “a great deal of this litigation has to be funded
by the government itself”—and the government can take away funds.
Welfare-reform statutes eliminate all statutory grounds for litigation
rights, except for constitutional grounds, which lawyers had
already failed on, he said.

Strategic litigation campaigns were made possible by the new
liberalism that emerged from the New Deal era, he said. President
Franklin Delano Roosevelt's strategic use of the Supreme Court
to weaken southern democratic opponents began the process of
consolidating liberals. By the late 1940s and early 1950s, liberalism
was seen as a package deal—if you were liberal on economic issues,
you were liberal on social issues.

“The Court's decision [in Brown] continues the process
that was initiated by Roosevelt 's economic program by attaching
the African-American community to the Democratic Party,” he said.
Johnson's Great Society program, which stressed social reform
and community values, further developed the new liberalism.

Brown and subsequent developments generated the southern
counter-strategy of attacking the Supreme Court as judicial activists.
This strategy repudiated the aspirations of the New Deal-Great
Society order. In both the Rehnquist Court —through its decision
to stop desegregation orders in Milliken (1976)—and
the Warren Court, “we see the Supreme Court collaborating with
the existing constitutional order.”

Kara Turner lectured on the
effects of a prolonged battle for integration in Prince Edward
County, Va.

Scholar Kara Turner, an Assistant Dean for Administration in
the College of Liberal Arts at Morgan State University, noted
that plaintiffs in the NAACP's strategic campaign to end segregation
may not have always been willing participants.

Before NAACP lawyers would act in the cases that made up Brown,
they asked plaintiffs to agree to pursue integration, rather
than equalization, of white and black schools. Turner alleged
that the students of Prince Edward County, Va. didn't really
have a choice—with disastrous results. The Prince Edward County
school for African-American students was “physically very very
inferior” to the white high school. Students had no cafeteria
or gym, and no lockers. When the county put up new buildings
to address black residents' concerns, they built tar-paper shacks,
which strangers thought were “chicken coops rather than a school
building.” Student Barbara Johns led a walk-out to protest the
conditions and contacted Richmond 's NAACP lawyers, who would
only take the case, Davis v. County School Board, if
the plaintiffs agreed to seek desegregation. “County residents
were sort of hijacked,” Turner said. The case became one of the
five cases included in Brown.

After Brown, the county closed public schools for
five years, while funding tuition grants for white children to
attend private schools.

“Despite the concerns of some local blacks [about the pursuit
of desegregation], few spoke out publicly,” she said, partly
because they admired the NAACP and because other lawyers were
not qualified to take the case. In a Richmond Times-Dispatch interview
several years later, more than half of the 19 plaintiffs said
they were not supportive of the desegregation suit. Some were
only recently aware they were even plaintiffs, she said, adding
that they may have said that to avoid the still-present threat
of reprisal.

Turner argued that events might have worked out less tragically “if
the black community itself had been able to decide whether to
pursue equalization or desegregation.”

When the county failed to desegregate after 1995's Brown II decision
ordering schools to desegregate with “all deliberate speed,” NAACP
lawyers appealed and the United States Court of Appeals for the
Second Circuit ordered the county to set a “reasonable start” date
for integrating schools. When the lower court set a start date
of 1965, the appeals court ordered the desegregation to start
that year. But in 1959 the Board of Supervisors adopted a budget
with no funding for public schools and changed the locks on school
doors. The 1,700 students locked out “have been called the crippled
generation and the lost generation, both apt descriptions.” About
300 were able to go to school elsewhere during the five years.

Many who lost five years dropped out when schools reopened,
finding that they were hopelessly behind; others graduated but
felt they couldn't make it in college. Some questioned their
self worth, because whites would rather close schools than attend
alongside them.

“They took something from me that could never be replaced, except
by disgust and hate,” one former student later said.

The county suffered some repercussions; no new industries were
established there during the period because there were no schools
for potential employees' children. From 1960-64 the NAACP represented
county students in a number of cases, challenging whether the
county could help finance private schools, for example. In 1964
the Supreme Court finally handed the lawyers a victory and the
district court ordered schools to open. However, only $189,000
was budgeted for public schools, while $375,000 was given to
whites for tuition grants, sending an “unmistakable statement
to blacks.”

Turner said whites didn't return to public schools in Prince
Edward until the 1980s. Black test scores still lag behind whites',
they are disproportionately placed in special education classes,
and they are rarely found in honors classes.

Asked whether any lawsuits have sought reparations for the affected
students, Turner said no one has tried yet, but “I think it's
a very clear-cut case.” Black residents recently had to pay $300,000
to buy the school students walked out of; they made it a civil
rights museum when the county refused to do so.

U.Va. law professor Michael
Klarman challenged the view “that
in some significant way Brown created the Civil Rights
Movement.” The court is never the vanguard in social causes,
Klarman said.

The Supreme Court had several reasons to strike down segregation
by 1954. African-Americans had fought for their country in World
War II and expected more rights; politicians were increasingly
bidding for the black vote in the north in the 1940s; Jackie
Robinson entered major league baseball in 1947; the military
and civil service desegregated in 1948; and the United States
was struggling against the Soviet Union for the loyalty of the
developing world, and “racial discrimination produced grist for
the Communist manuals.”

Justice Felix Frankfurter noted, “The pace of progress has surprised
even those most eager in its promotion.”

But "Brown forced people to take a position on school
desegregation, which none of them had done before,” Klarman said.
Many moderate southern politicians could not be moderate on desegregation,
or else lose their job. Northern politicians voiced support for Brown but
were unwilling to enforce it. Whites made up their minds “without
taking instruction from the justices.” Polls revealed no large
attitude shift as a result of Brown; a 5 percent increase
in support of the ruling seen in 1959 could have been influenced
by extra-legal forces, Klarman said.

Still, "Brown was of enormous symbolic importance
for African-Americans,” because it convinced them change was
possible. “There's no doubt that Brown facilitated
the motivation of civil rights protests.” Just signing a petition
to desegregate schools became an act of protest. "Brown clearly
prompted southern blacks to challenge Jim Crow more aggressively” than
they might have otherwise, Klarman said.

However, the evidence for Brown acting as a “spiritual
father” for civil rights protests is weak, and in the short term
the decision may have discouraged direct-action protest in favor
of litigation, as the dearth of protests from 1954-60 reveal. “After
the NAACP's inspiring victory, perhaps most blacks were inclined
to see in the short term what litigation could deliver,” he said.
In the long-term, Brown may have encouraged direct-action
protests by dashing the hopes raised by initial success in litigation.

In the meantime, white southern backlash stifled the litigation
movement. Following Brown, hundreds of NAACP branches
closed in the 1950s because of the backlash; some NAACP lawyers
had their homes fire-bombed and faced numerous other threats.
Other organizations like Students for a Democratic Society sprang
up to fill the gap, and by the time southern white violence was
broadcast everywhere in the early 1960s, “southern whites were
due to lose the battle for public opinion,” Klarman said. "Brown may
have directly fostered violence against southern blacks.”

Southern politicians indirectly encouraged such violence. Birmingham
police commissioner Bull Connor unleashed police dogs and fire
hoses against peaceful black protestors. Connor had actually
been pushed out of office by a sex scandal in the early 1950s,
after which the city had made progress on race, including building
the first hospital for blacks there. Connor made a political
comeback after Brown, and protest organizers picked
Birmingham in particular because they suspected the commissioner
would overreact.

George Wallace similarly became a “die-hard segregationist” after Brown and
won the governorship in 1962 (after failing as a moderate in
1958) on a promise to block the doors of schools from integration.
After blocking doors in locations across the state, Wallace backed
down when he was threatened with judicial contempt by five courts,
but soon after a black church was bombed and he received the
blame. Northern congressmen then introduced measures to make
the Civil Rights bill more aggressive.

Brown brought “to surface the violence that always
lay at the core of white supremacy,” Klarman said. "Brown was
less directly responsible for putting protestors on the street
and more directly responsible that they received a violent reception.”• Reported
by M. Wood

Law professor John Harrison
said the American judiciary will waver from the Constitution
on hot-button issues.

Brown's Impact on Constitutional Theory

Brown demonstrates that the Supreme Court deliberates and rules
within the prevailing national political context and is not a
lead agent of social change, according to a panel of leading
constitutional historians and theorists.

One lesson of Brown for constitutional theory is about
the difficulty of predicting and controlling the future, said
U.Va. law professor John
Harrison.

“The American judiciary is not the most faithful agent any one
has ever had. At various points they have defeated the expectations
of the framers.” They have strong opinions of their own and they
think about the political situation in which they are making
the decision. “They think like politicians about what is possible,” he
said.

The courts' fidelity to the framers' intentions and text “will
vary according to the felt importance of the issue,” Harrison
said. The more “hot button” the issue, the less likely the court
is to adhere strictly to the Constitution's text.

Thus the fate of amendments “generally relies pretty strongly
on judicial enforcement,” he said, and so the amendments' texts
need “strong clarity.” Of the Reconstruction amendments, the
15th “had a happier history than the 14th because it was a
lot clearer than the 14th. The framers of the 14th drafted
at a high level of abstraction, which meant they were less successful.”

Texts also profit from having “an entrenched provision,” he
said, something that draws a clear boundary and which typically
also offers political leverage in deals with opponents.

Yale law professor Akhil
Amar: “If you have to choose between separate and equal,
the Constitution says to choose equal.”

Judicial behavior over the Reconstruction amendments was also
suspect for Akhil Amar, a Yale University law professor.

If the Supreme Court's decision to repudiate Jim Crow laws affecting
education was right, then why did Brown take so long
to happen, he asked.

“The 13th Amendment gets rid of slavery forever,” Amar said. “Congress
has the power to get rid of all it badges and relics,” including
forms of discrimination that do not connect directly to slavery,
he said. “Congress had broad power to enforce the Reconstruction
amendments and if Congress had done what it should then Plessy would
have been a pre-emption case.”

Nor did the courts enforce certain provisions that they should
have. “Think about what the world would be if the Supreme Court
had enforced them.”

Amar said the framers of the 14th Amendment saw the equal protection
concept as implicit in the due process of law guarantee contained
in the Fifth Amendment. The 14th Amendment expressly named the
states because earlier Supreme Court decisions had said that
such explicit terms are necessary.

“Laws that disadvantage one race are inherently unequal. By
1954 it was clear to everybody that race discrimination is inevitably
unequal,” Amar said. “If you have to choose between separate
and equal, the Constitution says to choose equal.”

Amar said the Constitution should be considered holistically
and lamented a general public ignorance about its provisions. “Individual
clauses are nested in larger structural patterns,” he said. “The
14th Amendment is inherently integrationist and says all citizens
should be able to serve in legislatures and on juries,” he said
as an example.

Yale law professor Jack Balkin
said the Supreme Court was following the movement toward
rights for blacks, not leading it.

According to Yale University law professor Jack Balkin, the
main lessons of Brown for constitutional theory are
about what he called “positive theory,” meaning statements about “how
the machine works.” The first of those is that “the federal courts
are not counter-majoritarian,” he said, “but they do respond
to national elites and values over regional ones. By 1954 the
national majority thought Jim Crow was wrong and the elites thought
it was an embarrassment,” especially since segregation laws gave
the Soviet Union propaganda ammo in the competition for third-world
support. Similar changes happened with Lawrence v. Texas and Roe
v. Wade, Balkin said, when national majorities decided
they didn't want sodomy laws any more, in the first case, and
that abortion was a matter for a woman and her doctor to decide.

The second lesson is that “courts are bad at tackling but good
at piling on.” The real heroes of the reform movement were Jackie
Robinson, for daring to be the first black baseball player in
the major leagues, and Harry Truman for integrating the armed
forces, he said. The court was joining the movement more than
it was leading it.

Another lesson is that courts tend to protect minorities as
much as majorities want them to. “Wallace and Nixon appealed
to white resentment that things were changing too fast,” Balkin
said. Thus Milliken “gave a pass to suburban school
districts. You get the interpretation that is acceptable to majority
views,” he said. “Minorities need to show majorities how change
is in their interest.”

“At the end of the day it's about where the votes are,” summed
up Amar. • Reported by M. Marshall